ML15239A023
| ML15239A023 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/29/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| Shared Package | |
| ML15239A024 | List: |
| References | |
| NUDOCS 8907120089 | |
| Download: ML15239A023 (38) | |
See also: IR 05000269/1989001
Text
ACCELERATED
DISTRIBUTION
DEMONSTRATION
SYSTEM
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8907120089
DOC.DATE: 89/06/29 NOTARIZED: NO
DOCKET #
FACIL:50-269 Oconee Nuclear Station, Unit 1, Duke Power Co.
05000269
50-270 Oconee Nuclear Station, Unit 2, Duke Power Co.
05000270
50-287 Oconee Nuclear Station, Unit 3, Duke Power Co.
05000287
AUTH.NAME
AUTHOR AFFILIATION
EBNETER,S.D.
Region 2, Ofc of the Director
IR
RECIP.NAME
RECIPIENT AFFILIATION
TUCKER,H.B.
Duke Power Co.
SUBJECT: Forwards summary of presentation at 890421 meeting re SALP
D
Repts 50-269,270 & 287/89-01 for Aug 1987 -
Jan 1989.
DISTRIBUTION CODE: IE40D COPIES RECEIVED:LTR 4 ENCL _
SIZE:
2
S
TITLE: Systematic Assessment of Licensee Performance ,(.SALP) Report
NOTES:
RECIPIENT
COPIES
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COPIES
ID CODE/NAME
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ENCL
.32
Docket Nos. 50-269, 50-270, 50-287
License Nos. DPR-38, DPR-47, DPR-55
Duke Power Company
ATTN:
Mr. H. B. Tucker, Vice President
Nuclear Production Department
422 South Church Street
Charlotte, NC 28242
Gentlemen:
SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (NRC INSPECTION REPORT
NOS. 50-269/89-01, 50-270/89-01 AND 50-287/89-01)
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP)
report for your Oconee facility which was sent to you on April 11,
1989; our
meeting of April 21, 1989, at which we discussed the report; and your written
comments dated May 19, 1989.
I have enclosed a summary of our presentation at
the meeting, a copy of your written comments,
a copy of-the slides which were
used at the presentation, and the Final SALP report for the period August 1,
1987 -
January 31, 1989.
We appreciate your efforts in evaluating the interim SALP report and providing
corrections and clarification.
The following is our evaluation of your
comments:
Maintenance Surveillance
In your response, you expressed disappointment in the decline of the SALP
rating in this area.
You stated that your performance, although not
perfect, improved during the last SALP period and that this improvement
has continued through the current period.
We agree that the maintenance and surveillance programs are strong at
Oconee and over the SALP period Oconee had good availability and few
operational problems directly attributable to maintenance.
We also
acknowledge that your maintenance performance may not have declined since
the last SALP period.
As reflected in the SALP report, our perception of your performance~may
have changed because of the unusually intensive inspections which- fvealed
previously unrecognized problems.
Therefore, we continue to believe that
a Category 2 rating is appropriate.
FIA
AFDC
Duke Power Company
2
JUN 2 9 189
Security and Safeguards
In your response to the security area,
you again expressed your
disappointment in the SALP rating given.
You stated that you do not
believe your lack of resolution of the long-standing issue relating to the
assessment capability of the closed circuit television (CCTV)
and the
increase in the number of violations attributable to personnel error are
significant enough to result in the need to reduce the SALP rating from
the previous review period.
Although no single problem identified during the SALP period was overly
significant, the number of problems identified showed a distinct decrease
in the effectiveness of the security effort. Regarding the CCTV assess
ment, we do not agree that a lack of adequate CCTV assessment is a minimal
security system vulnerability.
A CCTV system is called for in the
regulations to facilitate initial response to an alarm and assessment of
threat, "to limit exposure of responding personnel to possible attack."
You have relied on compensatory measures, the use of responding guards, to
provide alarm assessment since identification of the problem almost two
years ago.
A compensatory measure is meant to be a short-term measure
providing the same or greater level of security prior to the degradation.
The use of responding guards does not provide immediate assessment as
could.
Although this finding resulted from the Regulatory
Effectiveness Review conducted in September 1985, the lack of
aggressiveness in pursuing long-term resolution of this issue continued
during this SALP period.
In your discussion of the violations issued during the SALP period, you
state that six of the violations were licensee-identified and should not
have been cited. Although they were identified by you, this is only one
criteria evaluated when deciding whether or not to issue a violation.
Additionally, you state that the violations do not reflect exploitable
weaknesses.
The issue of exploitability is considered when assigning a
severity level, not in whether to issue the violation.
Based on our evaluation in the SALP report and the discussion above, we
feel there has been a decline in the overall effectiveness in the Security
and Safeguards programs at Oconee and there should be no change in the
SALP rating.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10,
Code of Federal Regulations,
a copy of this letter with the
enclosures will be placed in the NRC's Public Document Room.
Duke Power Company
3
No reply to this letter is required; however, should you have any questions
concerning these matters, I will be pleased to discuss them with you.
Sincerely,
Stewart D. Ebneter
Regional Administrator
Enclosures:
1. SALP Presentation Meeting Summary
2. Written Comments Received
from Licensee
3. Copy of SALP Presentation
Slides
4.
Errata Sheet
5.
Final SALP Report as Revised
from Interim Report
cc w/encls:
M. S. Tuckman, Station Manager
State of South Carolina
bcc w/encl:
NRC Resident Inspector
L. Wiens, NRR
Document Control Desk
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ENCLOSURE 1
A. A meeting was held on April 21,
1989 at the Oconee site to discuss the
SALP Report for the period August 1, 1987 - January 21, 1989.
B. Licensee Attendees
W. H. Owen, Executive Vice President, Engineering and Construction
H. B. Tucker, Vice President, Nuclear Production
T. C. McMeekin, Vice President, Engineering
G. W. Grier, Manager, Quality Assurance
M. S. Tuckman, Station Manager, Oconee
C. NRC Attendees
S. D. Ebneter, Regional Administrator, Region II (RH)
C. W. Hehl, Deputy Director, Division of Reactor Projects (DRP), RII
A. R. Herdt, Chief, Reactor Projects Branch 3, DRP, RH
D. B. Matthews, Director, Project Directorate 11-3,
Office of Nuclear Reactor Regulation (NRR)
L. Wiens, Oconee Project Manager, Project Directorate 11-3, NRR
P. A. Skinner, Senior Resident Inspector, Oconee,
DRP, RII
L. D. Wert, Resident Inspector, Oconee, DRP, RH
ENCLOSURE 3
UNITED STATES
NUCLEAR REGULATORY
COMMISSION
SYSTEMATIC ASSESSMENT
OF
LICENSEE PERFORMANCE
(SALP)
DUKE POWER
COMPANY
AUGUST 1, 1987 through JANUARY 31, 1989
OCONEE UNITS 1, 2, AND 3
APRIL 21, 1989
SENECA , SOUTH CAROLINA
SALP PROGRAJI OBJECTIVES
1. IDENTIFY TRENDS IN LICENSEE PERFORMANCE
2. PROVIDE A BASIS FOR ALLOCATION
OF NRC RESOURCES
3. IMPROVE NRC REGULATORY. PROGRAM
asA
11
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DIVISION OF REACTOR PROJECTS
ORGANIZATION
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REACTOR PROJECTS
REACTOR PROJECTS
REACTOR PROJECTS
BRANCH NO. 1
BRANCH NO. 2
BRANCH NO. 3
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THOMAS E. MURLEY
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ASSOC. DIRECTOR
ASSOC. DIRECTOR FOR
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NRC
SALP PROGRAM
REVISIONS
MAJOR CHANGES TO THE
SALP PROGRAM CONSIST OF...
- Redefinion of Functional Areas
- Reduction in Number of Separate
Functional Areas
- Two New Functional Areas
- Engineering/Technical Ssupport
- Safety Assessment/Quality Verification
- Attributes Addressing Human Performance
and Self- Assessment
- Emphasis on Analysis
PERFORMANCE ANALYSIS AREAS
FOR OPERATING REACTORS
1. PLANT OPERATIONS
2. RADIOLOGICAL CONTROLS
3. MAINTENANCE / SURVEILLANCE
5. SECURITY
6. ENGINEERING / TECHNICAL SUPPORT
7. SAFETY ASSESSMENT / QUALITY. VERIFICATION
ENGINEERING/TECHNICAL SUPPORT
The purpose of this functional area
is to address the adequacy of technical
and engineering support for all plant
activities. It includes all Licensee
Activities associated with the design
of plant modifications; engineering and
technical support for operations, outages,
maintenance, testing, surveillance; and
procurement activities; training; and
configuration management (including
maintaining design bases and safety margins).
SAFETY ASSESSMENT/QUALITY VERIFICATION
The purpose of this functional area is to address the
technical adequacy and completeness of the licensee's
approach toward a va'iety of activities associated with
the implementation of licensee safety policies and
licensee activities related to amendment requests, exemption
requests, relief requests, response to generic letters,
bulletins, and information notices, and resolution of TMI
items and other regulatory initiatives. It also includes
licensee activities related to the resolution of safety
issues, 10 CFR 50.59 reviews, 10 CFR 21 assessments, safety
committee and self-assessment activities, analysis of
industry's operational experience, root cause analyses of
plant events, use of feedback from plant quality assurance
quality control(QA/QC) reviews, and participation in self
improvement programs. It includes the effectiveness of the
licensee's quality verification function in identifying
substandard or anomalous performance in monitoring the
overall performance of the plant.
PERFORMANCE RATING CATEGORIES
- Expanded discussion intent
- Redefinition of the categories to clarify
their meaning
AREA PERFORMANCE
CATEGORY I
UCENSEE MANAGEMENT ATTENTION AND INVOLVEMENT
ARE READILY EVIDENT AND PLACE EMPHASIS ON SUPERIOR
PERFORMANCE OF NUCLEAR SAFETY OR SAFEGUARDS
ACTMTIES WITH THE RESULTING PERFORMANCE SUB
STANTIALLY EXCEEDING REGULATORY REQUIREMENTS.
LICENSEE RESOURCES ARE AMPLE AND EFFECTIVELY USED
SO THAT A HIGH LEVEL OF PLANT AND PERSONNEL
PERFORMANCE IS BEING ACHIEVED. REDUCED NRC ATTENTION
MAY BE APPROPRIATE.
AREA PERFORMANCE
CA TECORY 2
LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT
IN THE PERFORMANCE OF NUCLEAR SAFETY OR SAFEGUARDS
ACTIVITIES ARE GOOD. THE UCENSEE HAS ATTAINED A
LEVEL OF PERFORMANCE ABOVE THAT NEEDED TO MEET
REGULATORY REQUIREMENTS. UCENSEE RESOURCES ARE
ADEQUATE AND REASONABLY ALLOCATED SO THAT GOOD PLANT
AND PERSONNEL PERFORMANCE IS BEING ACHIEVED. NRC
ATTENTION MAY BE MAINTAINED AT NORMAL LEVELS.
AREA PERFORMANCE
CA TECOR Y J
UCENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT
IN THE PERFORMANCE OF NUCLEAR SAFElY OR SAFEGUARDS
ACTMTIES ARE NOT SUFFICIENT. THE UCENSEE'S
PERFORMANCE DOES NOT SIGNIFICANTLY EXCEED THAT NEEDED
TO MEET MINIMAL REGULATORY REQUIREMENTS. UCENSEE
RESOURCES APPEAR TO BE STRAINED OR NOT EFFECTIVELY
USED. NRC ATTENTION SHOULD BE INCREASED ABOVE NORMAL
LEVELS.
OPERATIONS PHASE, VIOIATIONS/OPERATING REACTOR
AUGUST 1, 1987 through JANUARY 31, 1989
40
LEGEND
35
R II AVE
N
OCONEE
30.-UT1ITIES
OU
b.
0
GPC
R1l AV
APC
VEP
OCONEE
SERI
ULIUTY
ALLEGATIONS PER UTILITY/SITE
AUGUST 1, 1987 through JANUARY 313 1989
2
LEGEND
RII AVE.
Is.
OCONEE
UTIUTIES
O 14
z
0
< 12'
LTII
0
I
w
4
GPC
SERI
VEP
APC
OCONEE
RII AVE.
UTILITY
EVALUATION CRITERIA
1. MANAGEMENT INVOLVEMENT IN ASSURING QUAITY
2. APPROACH TO RESOLUTION OF TECHNICAL ISSUES
FROM A SAFETY STANDPOINT
3. RESPONSENESS TO NRC INITIATIVES
4. ENFORCEMENT HISTORY
5. REPORTING AND ANALYSIS OF REPORTABLE EVENTS
6. STAFFING (INCLUDING MANAGEMENT)
7. TRAINING EFFECTIVENESS AND QUALIFICATION
VIOLATION SUMMARY
AUGUST 1, 1987 through JANUARY 31, 1989
1i
111V
v
OCONEE UNIT 1
0
0
1
16
5
OCONEE UNIT 2
0
0
1
16
5
OCONEE UNIT 3
0
0
1
19
7
REGION11 AVE.
0
0
2
20
5
PER UNIT
LERs PER UNIT
AUGUST 1, 1987 through JANUARY 31,1989
40
38
LEGEND
a
NATL AVE.
34
33
OCONEE
PLANT TYPE
25
21
0
w
hJ
0
z Z 15
10
10
WE NATL AVE.
BW
OCONEE
PLANT TYPE
OCONEE LERs
AUGUST 1,
1987 through JANUARY 31, 1989
a
29
LEGEND
PERSONNEL (other) = 4
PERSONNEL (test/cal)
6
PERSONNEL (maintenance)
2
O7 PERSONNEL (operating)
3
OTHER = 3
S15
COMPONENT FAILURE = 4
DESIGN / CONST. = 7
z
U
PERSONNEL (total) x 15
PLANT
PERSONNEL
OCONEE LERs
(PLANT)
AUGUST 1, 1987 through JANUARY 31, 1989
DG/NPERSONNEL
5C1A.7%
OTHER
1 0.3%
24.1%
1 3.8%
DESIGN/CONST.
COMP. FAILURE
OCONEE LERS
(PERSONNEL)
AUGUST 1, 1987 through JANUARY 31, 1989
TEST/CALIB.
40%
MAINTENANCE
13.3%
OPERATIONS
OTHER
20%
28.7%
FUNCTIONAL AREA COMPARISON
FOR REGION 11 FACILITIES
CYCLE VI
14
LEGEND
121
ECATEGORY 1
CATEGORY 2
to
.
CATEGORY 3
O
Z
.
W",
z
4
2
9--
-1
00
00
0
MAINT
EM PREP
RAD CON
SURV
FIRE PROT
FUNCTIONAL AREA
FUNCTIONAL AREA COMPARISON
FOR REGION 11 FACILITIES
CYCLE VI
14
LEGEND
12
E CATEGORY 1
CATEGORY 2
to
CATEGORY 3
0O
to
z
2
00
0
00
SEC
OUTAGES
TRNG ENGR SUP
FUNCTIONAL AREA
PLANT OPERATIONS - CATEGORY 1
o
OVERALL PLANT OPERATIONS WAS A STRENGTH
o
MANAGEMENT
SUPPORT AND
INVOLVEMENT
IN ALL ASPECTS OF
PLANT OPERATIONS WERE EVIDENT
o
CONTROL ROOM DEMEANOR AND ATTENTIVENESS WERE GOOD
o
CONTINUED REDUCTION IN AUTOMATIC REACTOR TRIPS
o
EMERGENCY PROCEDURES AND ABNORMAL PROCEDURES ADEQUATE
o
WEAKNESSES IDENTIFIED IN COMMUNICATIONS, AND TRAINING OF
OPERATORS AND SUPERVISORS
o
IMPLEMENTATION OF FIRE PROTECTION PROGRAM MET NRC
COMMITMENTS
o
PLANT HOUSEKEEPING CONTINUED TO IMPROVE
RADIOLOGICAL CONTROLS - CATEGORY 1
o
STRONG MANAGEMENT SUPPORT AND INVOLVEMENT
o
AGGRESSIVE CONTAMINATION CONTROL PROGRAM
o
COLLECTIVE DOSE LOWEST SINCE 1975
o
RADIOACTIVE EFFLUENTS WERE WITHIN REGULATORY LIMITS
o
WEAKNESSES INDENTIFIED IN CONTROL OF ACCESS TO RADIATION
AREAS
o
ATTENTION
TO OPERATION AND MAINTENANCE
OF PROCESS AND
EFFLUENT MONITORS NOT SUFFICIENT
MAINTENANCE/SURVEILLANCE -
CATEGORY 2
o
OVERALL MAINTENANCE/SURVEILLANCE PROGRAMS WERE EFFECTIVE
o
MANAGEMENT SUPPORT AND INVOLVEMENT IN MAINTENANCE
PROGRAM WAS APPARENT
o
QUALITY OF MAINTENANCE
AND SURVEILLANCE
PLANNING WAS
GOOD
o
WEAKNESSES
IDENTIFIED
IN 50.59
REVIEWS
AND
COMMUNICATION/COORDINATION
o
NUMEROUS
MAINTENANCE
PERFORMANCE
PROBLEMS
WERE
IDENTIFIED
o
PERFORMANCE IN THE SURVEILLANCE AREA MIXED
CATEGORY 1
o
DEMONSTRATED
OVERALL ABILITY TO IMPLEMENT
THE CRITICAL
ASPECTS
OF
EMERGENCY
PREPAREDNESS
DURING
SIMULATED
ACTUAL EMERGENCY EVENTS
o
SATISFACTORY
PERFORMANCE
DURING APRIL 1988 FULL SCALE
EXERCISE
o
WEAKNESS NOTED FOR INCORRECT EMERGENCY CLASSIFICATION
o
SATISFACTORY
CAPABILITY
FOR
PROMPT
NOTIFICATION
AND
EFFECTIVE COMMUNICATIONS
o
A STRONG COMMITMENT TO EP TRAINING NOTED
SECURITY AND SAFEGUARDS -
CATEGORY 2
o
AUTHORITIES
AND RESPONSIBILITIES
WERE CLEARLY DEFINED
AND EFFECTIVE
o
CONTRACT FORCE ADEQUATELY STAFFED AND APPROPRIATELY
TRAINED AND EQUIPPED
o
INDEPENDENT AUDITS THOROUGH
o
CONCERN REGARDING CCTV ASSESSMENT CAPABILITY
o
RELIANCE ON LONG TERM COMPENSATORY MEASURES NOTED
o
ADHERENCE TO PROCEDURES AND DOCUMENTATION PROBLEMS
o
ADEQUATE SAFEGUARDS PROGRAM FOR THE CONTROL OF BOTH FUEL
AND NON-FUEL SNM
ENGINEERING AND TECHNICAL SUPPORT -
CATEGORY 2
o
ENGINEERING AND TECHNICAL SUPPORT WAS GENERALLY GOOD
o
DESIGN
ENGINEERING
ACTIVITY
RESULTED
IN A NUMBER OF
SELF-IDENTIFIED PROBLEMS AND IMPROVEMENT INITIATIVES
o
MAINTENANCE ENGINEERING SUPPORT EFFECTIVE
o
OVERALL QUALITY OF ENGINEERING
AND TECHNICAL
SUPPORT
COMPROMISED BY WEAKNESSES IN COMMUNICATION
o
OPERATOR TRAINING AND REQUALIFICATION TRAINING PROGRAMS
GENERALLY GOOD
o
SIMULATOR TRAINING STAFF SUPPLEMENTED
WITH EXPERIENCED
OPERATORS
o
SIMULATOR GENERALLY UPDATED HOWEVER MINOR HARDWARE AND
SOFTWARE NON-CONFORMANCES IDENTIFIED
SAFETY ASSESSMENT/QUALITY VERIFICATION -
CATEGORY 2
o
MANAGEMENT INVOLVEMENT IN LICENSING ACTIVITIES EVIDENT
o
ACTIVE PARTICIPANT AND LEADER
FOR INDUSTRY
INVOLVEMENT
IN GENERIC ISSUES
o
CONCERN REGARDING TIMELY RESOLUTION OF ISSUES FOR OCONEE
o
LERS
SUBMITTED
WERE
GENERALLY
WELL WRITTEN
AND
HAD
SUFFICIENT DEPTH
o
TIMELY, SOUND RESPONSES TO GENERIC LETTERS AND BULLETINS
o
DEMONSTRATED
CAPABILITY
TO IDENTIFY AND RESOLVE PLANT
PROBLEMS
o
10 CFR 50.59 EVALUATION PERFORMANCE MIXED
o
COMMUNICATIONS
HAVE
HINDERED
RESOLUTION
OF PROBLEMS;
IMPROVEMENT NOTED DURING LATTER PORTION OF PERIOD
SUMMARY OF RESULTS
o
OVERALL, PLANT WAS OPERATED IN A SAFE MANNER
o
STRENGTHS IN THE AREAS OF PLANT OPERATIONS, RADIOLOGICAL
CONTROLS AND EMERGENCY PREPAREDNESS
o
IMPROVEMENTS
IN THE AREA OF SAFETY ASSESSMENT/QUALITY
VERIFICATION
o
PROGRESS IN THE AREA OF ENGINEERING TECHNICAL SUPPORT,
HOWEVER WEAKNESSES STILL EXIST SUCH AS THOSE ASSOCIATED
WITH COMMUNICATIONS
o
MAINTENANCE/SURVEILLANCE AND SECURITY PROGRAMS VIEWED AS
STRONG,
HOWEVER A DECLINE IN PERFORMANCE
WAS NOTED IN
THESE AREAS